July
15,
2005
MEMORANDUM
From:
Michael
Galbraith,
USEPA/
OSW
To:
Hazardous
Waste
Combustor
MACT
Rule
Docket,
OAR
2004­
0022
Subject:
Telephone
Conversation
with
Utah
DEQ
Regarding
2001
Clean
Harbor
Emission
Test
On
May
12,
2005,
I
had
a
telephone
conversation
with
Rick
Page,
who
is
a
RCRA
permitting
official
for
the
Utah
Department
of
Environmental
Quality.
I
requested
Mr.
Page
to
assist
me
in
addressing
a
comment
we
had
received
on
our
proposed
MACT
rule
for
hazardous
waste
combustors.
The
commenter
claimed
that
Clean
Harbor's
Aragonite
facility
encountered
problems
with
their
carbon
injection
system
during
their
2001
emissions
test.
As
a
result,
the
commenter
claimed
that
EPA
should
not
use
the
dioxin/
furan
emissions
data
from
this
test
to
calculate
MACT
floors.

Mr.
Page
verified
that
Clean
Harbors
communicated
to
UTAH
DEQ
that
they
did
in
fact
encounter
problems
with
the
carbon
injection
during
this
emissions
test.
More
importantly,
Mr.
Page
indicated
that
operating
parameter
limits
for
the
carbon
injection
system
(
e.
g.,
carbon
injection
rate)
were
not
established
as
a
result
of
this
emission
test.
